Privacy Policy

Last modified: September 6, 2018

At SEVEN Networks, LLC (“SEVEN”, “us,” “our,” or “we”) we recognize and respect your privacy. We have created this Privacy Policy (the “Policy”) to explain our privacy practices regarding the information that we collect from you through the AdClear, Dubbel, or our other mobile applications (the “App”). This Policy explains how SEVEN and its affiliates and subsidiaries (“Affiliates”) collect, use, disclose, and protect this information. This Policy also explains your choices regarding our information practices. If you have any questions, please contact us at support@seven.com.

 

Policy Highlights

 

Aspects of this Privacy Policy are highlighted below only for your convenience. These highlights do not substitute, replace, or override any aspect of the full Privacy Policy.

Information collection

When you use the App, you choose to route some or all of your device's data traffic through or to, the App. We automatically collect some information routed through the App, such as information about your device, mobile applications, and data usage. You also may provide us with certain personal information when you use the App.

Use of information

We use the information we collect, including to provide the App and its services to you, analyze usage of our App and other applications on your device, improve the App, communicate with you, and provide analytics and other services to third parties.

Sharing information

We may share, sell, transmit, or otherwise make available to third parties information that does not identify specific persons without restriction. Other than the limited circumstances described in this Policy, we do not make your personal information available to third parties unless the information sharing is described to you at the point of collection or we obtain your consent.

Your choices

You may choose not to provide the personal information we request. However, not providing information we request may restrict your ability to use certain App features. If you do not wish for the App to collect information about you in accordance with this Privacy Policy you should refrain from using the App and delete the App from your device. Under certain circumstances, you may make certain choices related to your information, such as requesting access to your information or requesting that we delete it.

Security

We maintain safeguards to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information we receive.

International transfers

We may store and process information, including through third-party or Affiliate hosting services, in the United States, EEA, and other international jurisdictions, including jurisdictions that may not have been deemed by the European Commission to provide a comparable level of protection to your data as that of the EEA.

Third party activities

If you view third-party websites or use third-party applications or services while using the App, then this Privacy Policy will not apply to information collected by that third party's website, application, or service.

Changes to this privacy policy

If we make any material changes to this Privacy Policy we will notify you by email, through prominent notice in our Apps, or by posting a prominent notice on our Website.

Contacting us

If you have any questions or comments about this Policy or our privacy practices, please contact us at support@seven.com.

 

Full Privacy Policy

We collect, use, share or otherwise process your personal information, as described in further detail below, when we have an appropriate basis for doing so. For example, we may process your personal information as necessary to provide services, such as the App, that are subject to terms you have accepted, such as our end user license agreements or Terms of Use. We may process your personal information for purposes of pursuing our legitimate interests, if doing so is consistent with your rights and appropriate to the context, such as to provide and improve our products and services; to communicate with you; to perform business analysis and research; to provide analytics services; to prevent fraud; to enforce legal claims, our policies, and terms; in connection with a transfer of assets; and for security purposes. We may also process your personal information to comply with legal obligations or when we obtain your consent to do so.

Information You Provide

You may provide us with certain personal information when you use the App. For example, we may collect your email address when you request support through the App. Additionally, if you otherwise contact us, we may keep a record of your communication, contact information, and other information you provide to us.

Information We Collect Automatically

When you use the App, you choose to route some or all of your device's data traffic through, or to, the App. The App processes this information on your device in order to provide ad-blocking services. For example, the App will analyze outgoing data and, when it identifies requests to retrieve ads, the App will block the request. The App will also analyze information your device transmits to facilitate ad-blocking services. Generally, the data transmitted through or to the App resides on your device, and we do not collect it and store in on our servers. However, we may automatically collect some information routed through the App, such as the following:

We may use the information we collect, including personal information, to provide products and services and to support our business functions. For example, we may use this information to:

We retain personal information for as long as we reasonably need it to fulfill the purposes described in this Policy, comply with our legal obligations and policies, resolve disputes, and enforce our agreements.

We may share, sell, transmit, or otherwise make available to third parties aggregate and/or anonymized information. This data may provide insights into trends in mobile, app, online, and advertising activities, among other things. For example, we may provide aggregate information to a third party on how many ads the App blocks over a certain period of time or user application usage patterns. In connection with providing that aggregate data, we may also provide, for example, data showing how many ads have been blocked or application usage patterns on/for several specific users' devices to allow the third party to better understand the aggregate data we are providing to them; that data will not identify the specific user.

 

We may share personal information (as well as non-personal information) in the following instances:

You may choose not to provide the personal information we request. However, not providing information we request may restrict your ability to use certain App features. For example, you may be able to restrict the collection of personal information or functionality through your device's operating system, but doing so may prevent you from using the functionality of the App.

You may be able to control many tracking tools, including cookies, from your browser. In particular, you may refuse to accept browser cookies by activating the appropriate setting on your browser. However, this browser setting may not apply to your use of the App. If you do not wish for the App to collect information about you in accordance with this Privacy Policy you should refrain from using the App and delete the App from your device. For example, to opt out of future collection of information we use in connection with Google Analytics for Firebase features we have implemented, described above, you must stop using and uninstall the App.

Some Internet browsers have a 'do not track' feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform and may not apply to the App, so we are currently not set up to respond to such signals.

If you stop using the App, you can request that we remove the personal information that we collected from you through the App by contacting us at support@seven.com. Users of the App may review or modify their personal information collected and stored by SEVEN through their use of the App by contacting us at support@seven.com. If you are located in the European Economic Area ("EEA") or Switzerland, then you may have the right to request access to, correction of, erasure of, or the transfer of your personal information, as well as the right to object to or restrict the processing of your personal information. You can exercise these rights, if applicable, by contacting us at support@seven.com. We may not be able to accommodate all requests, such as when we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We maintain safeguards to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information we receive.

We may store and process information, including through third-party or Affiliate hosting services, in the United States, the EEA, and other international jurisdictions. As a result, we may, with your consent, transfer the personal information described above from your device to a jurisdiction with different data protection laws than the jurisdiction in which you are located or reside for the purposes described above. Some of these jurisdictions may not have been deemed adequate by the European Commission to provide a comparable level of protection to that of the EEA or Switzerland. However, we will treat your personal information as subject to, and protect it in accordance with, this Policy. You may use the App's settings menu to withdraw your consent to transfer your personal information as described in this paragraph.

Third party websites, applications, and other services accessed while you are using the App are not under the control of SEVEN and SEVEN shall have no responsibility or liability for the content or privacy practices of any such websites, applications, or other services or any link at any time. If you view third-party websites or use third-party applications or services while using the App, then this Privacy Policy will not apply to information collected by that third party's website, application, or service, and you must read the privacy policy associated with that website, application, or service to determine how your information will be collected, used, and disclosed. We do not allow third parties to use the App to collect personal information about your online activities over time and across different websites, applications, and other online products or services. However, websites, applications, and other online products or services that transmit traffic through the App may engage in such collection or permit other parties to do so. For example, a website that you access may collect personal information about your web browsing history across multiple websites over time or allow another party to do so.

We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. If we make any material changes, we may notify you by contacting you through our services, emailing you (to the address specified in your account, if we have an address for you), or by posting a notice on the App or our website-or by some combination of these methods. We encourage you to periodically review this Policy for the latest information on our privacy practices.

If you do not agree to any modifications to this Policy, your sole recourse is to immediately stop all use of the App. Your continued use of the App following the posting of any modifications to this Policy will constitute your acceptance of the revised Policy.

If you have any questions or comments about this Policy or our privacy practices, or to report any violations of the Policy or abuse of the App, please contact us at support@seven.com.

© 2018 Seven Networks, LLC